Document OzZJLVwdzzM8qKnpLQB1avL1e

FILE NAME: Avondale (AVD) DATE: 197^ DOC#: AVD DOCUMENT DESCRIPTION:h^Z>ZWZZEZ^Z hZZZZZZKZ// U.S. DEPART1'~ZN r OF L.ABCR Bureau of Labor Statistics Washington, D. C. 20212. September 28, 1970 Mr. Francis L. LaQue, President American Nationai Standards Institute 1430 Broadway New York, New York 10018 Dear lvir. LaQue: 1 am pleased to submit to you the report of the Study Group on Reporting Vlork Injuries on a Nationwide Basis, which you appointed in January of this year. We have prepared a proposed National System for Uniform Recording and Reporting of Gccupational Injuries and Illnesses, reflecting the consensus of the study group. It is enclosed as Exhibit I, togeG1er with a report on our work as Exhibit II. fhe study group has completed its form.al assignment and should be discharged. In a very real sense, however, the work of the study group has just begun. Departures from 1ong .. establish~d modes of thought are sug-gested and a new method of measuring occupational safety and health proposed. We recognize that there are controversial aspects to the proposal. A thorough review by those with an interest in the subject is required. The study group did no~ clear our proposal with the groups from which we came or with others, It is recognized that the system needs testing in use. Gn behalf of the members of the study group and those we invited to consult with us, I thank you or the opportunity to participate in this useful and important work. Yours most sincerely, \/) { l Y\Qu_.\t.q_ -71i:/J/.)f1):,/4r.l,{/; w ... Maurice F. Bresnahan Study Group Chairman Enclosures PLAINTIFF'S EXHIBIT SBCA 5074 Proposed National System for Uniform Recording and Reporting of Occupcttional Injuries and Illnesses CON'fENfS 1. Introduction-------------------------------------- Page 1 2.. Definitions --------------------------------------- l 3. 1 Cccupational Injury and Illness F..ecords ------------ 3 3. . P~nnual Report ----------------------------------- 3 3. 2. 2 Instructions for Completing Annual Report -.------ 5 4. Categories of Reportable Gccupational Illnesses------ 8 5. Log-~------------------------------------------- 10 &. Annual Summary ---------------------------------- 7. F..e porting !v.Lethod --------------------------~------ 12 C. Cata Gutput 0 the Sy.stem ------------------------- 12 c-- EXHIBI r I PRCPGSED NA l'IC N.AL SYSTEl\li FOR UNIFCRM RECORDING .AND R~PC,R TING (;F CCCUPATIC.NAL INJURIES AND ILLNESSES August 21. 1970 Proposed National System for Uniform P.ecording and Reporting of Occupational Injuries and Illnesses 1. Introduction The National System proposed herein is designed to provide an annual profile on the m.unbers of occupational injuries and illnesses occurTing in the American work place. The measurement will provide indicators as to where occupational safety and health problems exist and can be used as a guide for those responsible for the prevention of. future occupational fatalities 1 injuries and illnesses. 2. Definitions . In this reporting system the following definitions sh~.11 apply: 2. l A Reportable Gccupational Iniury or Illne.s.s is any disability or permanent impairment to an employee which results from any exposure in the work environment that ei~her: l. Results in death; or 2. Prevents the employee from performing his normal assign- ment during his next regular or subsequent work day or shift; or ,. 3. Requires 2 or more visits to a physician. 2. 2 An Occupational Injury is any injury such as a cut, fracture, sprain, amputation, etc., which results from a work accident. 2. 3 An OccuEational Illness of an employee is any abnormal physical condition or disorder, other than one resulting from an occupational injury, ca.used by exposure to envirorunental factors associated with his employm~nt. It includes acute and chronic illnesses or diseases which may be ca.used by inhalation, absorption, ingestion or direct contact and which can be included in categories 1 through 7 listed in Section 4. Z. 4 Classification of Reportable Occupational Injuries or Illnesses The following classifications shall apply to reportable occupational injuries or illnesses: l. Fatalities: Injuries and illnesses that result in the death of any employ-ec regardless of the time lSet:ween the injury or the diagnosis of illness and death. - 2- 2. Lost Time Cases: Injuries and illnesses other than fatalities that prevent the employee from performing his normal assignment during any part of the next regular or any subsequent work day or shift. 3. Tcwo- Visit Physician freatment Cases: Injury and illnesses, other than fatalities and lost time cases, that require Z or more visits to a physician. 2. 5 Cccupational Injury ~nd Illness Records. A recording of each reportable occupational injury ( including fatality) and illness is required of every employer covered by the reporting system. 2. [> Annual Summary is a compilation of the total number of reportable occupational injuries and illnesses ( including fatalities) by classificatior.1 for posting by employers in a manner accessible to the employees. 2. 7 Annual Report is a report of occupational injury and illness data that is to be completed and submitted upon the request of the Secretary oi Labor. 2. 8 VTork Days Lost. The actual number cf days the employee would have worked but could not bec..?.use of an occupational injury or illness. 2. 9 Establishment. An economic unit which produces goods or services, and generally is in one physical locatj.on ,;n_?aged in one economic activity. - L. 10 VJ ork Environment is comprised of the physical location, equipment, materials processed or used, and the kinds of operations performed by an employee in the performance of his work. t.. 11 1-ian- Hoursi,;;,i orkeci. In the reporting systen1, man-hours will be used as the common denominator and is the total hours Worked by the employees durin.~ the reporting period. To make the rates more meaningful, they will be presented in terms of "per 100 full-time employees. 11 3 Occupational Injury anc1. Illness F:.eportin1; System 'l'he uniform system of recordiniY and reportin<Y occupational inJuries and '11 ' :=- 1 ~esses consists of a required Annual Report Form, Section 3 .:;. l; a required Annual Sununary, Section :.i and a auogested Lo 0 .~..e cti on .;, ' .c, ol .. 3. 1 Occupational Injury and Illness Recor::?s 3.1.1 Records Each occupational injury ~ncluding fatality), and illness shall be recorci.ed by every employer using his own record keepin:; system, whicl1 can be a first report of injury or equivalent form. The sug~ested Log of Section 5 can also be used. fhe records shall be usee:. as a source for completin.] the Annu.ll Report of Section 3. 2 and the Annual Sum- I, .. mar1, of 3ection .'.,. ' .J Every occupational illness, dia:;nosecl by a physician as inclu,Le<l in foe definition of Section 2. 3, and reported to the employer, shall be recOrlLeG., provided the e_.:tent of disability is t ~1at of one of t.:1.e classes of Section 2. 4 . . 3.?. Annual Report. The annu2.l report which s~1.all be completed ami filed wit1 tne Secretary of Labor, upon request, -is that report form described in Section 3. 2. I. 3. 2. l Annual Repo1"t Form r OCCUPATIONAL INJURY AND ILLNESS REPORT FOR 1970 Individual titablishme!lt repon:s will only be available for statistical compilation, inspection services, and consultation service~. Information will not be published so that the individual esrab l ishrnent can be identified or its re~rt deduced. L Code5 =--r~__.!__._1__.____._ _I _jI {Pleaa, c"4ngfS maili1tg addre11s if ineo,.,.ect-Indude poata.l ZIP code) Establishment name and location - - - - - - - - - - - - -- - - - - I. Employment and Hours. .(See inatructions 1,) (PloaM com11lto thi aect.lon v~n U10u11h thN wen no lnjurlu.) 1. Average nwnber of full- and part-time employees (Enter average of year; include all classes of employees) ... - 2. Total ho11n1 worked by all em ployees during entire year . . --- ... . II. Nature of Business. (See iru1truetion11 11.) 3. Principal type of activity of this establishment (i.e., ms.nu !actunng, wholesale, retail, construction, hotel, etc.)~ .............................................................................................. 4. Enter in ol'der of imp,,rlance the principal l"T'efl>t ,.f total prod.ucta manu.factured, lines ot trade, annlla.l uJ,. value apec1fic aervicea, o?' other activities. ' ."' -lr>t.o, 19?.Q. (a) --- (b) ----- (c:) ---- (d) ------------- (.) ------. - % ---% - % - - - o/o -------% 5. For manulacturing only, ind'icate: (a) Prineitial materials used {e.w.. Alumln.... c:ut.101111, ma- cl>Jned part,,, JUMnsbltd part.a: l'&J'On 1uapl, wool 7U"II, cocton fahrlea, t.e.-ln lhe forTD broucbl !11t.o plan\; do no(. lln IDAt.eria.l pracluee:1 la I.Ala plant.) (b) General types of operation perlormed (e.g., foun~ry, machine shop, assembly; apinning, weaving-, aewmii, etc.) ------ III. Reportable Occupational Inju:;-ies and Illnesses (See iulructlona 111,) Fnallties (1) Lost Time Cases Number !Work Da,S of Cases Lott (2) (3) TwoVisll Phy~1c1an Treatment Cases (4) (a) Occupational Injuries (b) Occupational Illnesses 1, Occupational skin dbeases or disordel'S 2. Dust diseases of the lungs (pneumoconioses) 3. Ro?sp1r:1tory conditions due to toxic agents 4. Poisoning (systemic effects of toxic materials) S. Disorders due to physical agents (other than toxic materials) 6. DisordeN due torepe:ited trauma 7. All other occupatjonal illnesses Tot:il -- occupaLion1d illnesses.( 1-7) r:i.' ~ . '(- - c) Tot:- - - 1! --Occu -pat1-on_a-l_'.I.n..:j._u-_ri-c.s::a_n_-d_-..I-.1..l-nes-ses- - - - - - - _ _ L . - - - L - - --J.-_-__-___._ __ Coaunent.,: ------------ ...... - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - - - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .<It .................................................................... - - - .... "' ........................ - - - - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - - - - - - - - - - - - - Report prepared by............................................. Poeition............................................... Oat.! .........................:......... . - 5- J. 2. 2 Instructions for Completin:.; the Annual Report Form 3. z. 2. 1 (iene ral a) This :report is require4. upon request of 6.e Secretary of Labor b} 'fhe annual report period shall be for a calendar year, with the report to be completed by January 30, the followin::; year. Esta!Jlishment Name c>_nd Location: Enter the location if different from the mailing address anC: b1~ name, number, or ot:1er c}esignation that identifies t.i.u.s establishment. 3. Z. 2. 2 Specific Instructions I. Employment and Hours Item 1. Employees. --Enter the avera~e number of employees for t~1e year. Include all classe~ of employees ( administrative. supervisory. clerical, professional, tec~1n:fcal, sales, deHvery, installation, construction and service personnel, as well as operatinr:: anc7- related workers) employed full- or part-time by this establislnnent. fo obtain bus fiJure ( a) ae:d the nurnber of employees re-ported to your State Unemployn:ent Insurance Agency for each n:onth an:l divi;e 1)y- 12, or (b) acci the number on each pa;l"oll Jurin:; tl1e year and divi-....e by the number of suc:1 payrolls in t.1e year. Iten1 t... ~-fours. - -I.:nte r the total hours wor~ced 'oy all employees ,~urinw: t.1e entire year. Include all time on duty, but e.:clude vacation, ~101i.Ja7, sick lec.ve, and all ot.1er off-duty time, ~ven t ..1ou h pai:.: for. fhe hours reportecl s1.ouU 0e obta:i,nec'. from payroll or other time recor<l~. If actual hours of office, sales, or other 2,roups are not availa'.Jle, t:.1ey may tie estimated on tl1e basis of sc~1eciule6 hours or 8 hours per day. (E;cample: If 10 empioyees worked e hours per cay, :> days a week, for :>O weeks the total would be 1 OXL.X:,:C:..0=20, 000 hours or t~1e year. ) Allcwanc e s houlcl be made for overtime, slack periods, irre:-;1.1lar and part-time work, holidays, vacations, anci ot~1er absences. For stand0y err_ployees su61 as seamen, firemen, emer~ency crews, etc:, use t~1e number of hours the employee is_ confineo to the employers premises, up to 2.~ nours per daJ, For employees livin_; on the property i.mt not confine.: to it, use t:1e actual hours worked. Include actual hours worked by casual employees. II. Nature of Business Under Item 3, inc1icate t~e zeneral type of activity, and un:'.er item. ~ list the specific pro<lucts manufactured, lines of trade, services, or other activities engaged in. Please describe each product or activity fully.. (Example! Manufacturing upholstered household furniture, retail men's shoe.s, auto body repair, etc.) Ii more than one product or activity is listed, show in the second column the approximate percent of totp.l annual sales value or receipts derived fr_2m each. If engaged in manufacturing> please list under 5(a) the principal materials used (in the form in which they were brought into establishment), and under (b) indicate the general types of operations performed by this establislunent. lII. Reportable Occupational Injuries and IllD.esses Enter the total nu.rnber of fatal cases, lost time cases, and two-visit physician treatment cases ( These make up reportable injuries and illnesses.) for each of the classes of occupational injuries and illnesses listed. Include all reportable injuries and illnesses incurred by employees of the establishment during the calendar-year. If the final extent is not known by the reporting date ( February 1 of the following year) use the doctor 1 s best estimate. Ii you are W1able to estimate final extent, give details of the case in "Comments. 11 For lost time cases, enter the number of work days lost. 11 the re is none, enter 11 0 11 in the box. -7 A Reportable Occupational Iniury or Illness is any disability or permanent impairment to an employee "".hich results from any exposure in the work enviromnent that either: . 1. Results jn death; or z. Prevents the employee from performing his normal assignment during his next regular or subsequent work day or shift; or 3. Requires 2. or more visits to a physician. Fatalities: ( column 1) Injuries and illnesses that result in the death of any employee regardless of the time between the injury or t?e diagnosis of illness and death. Lost Time Cases: ( colunrn 2.} lnjurie s and illnesses other than fatalities that prevent the employee from performing his normal assignment during any part of the next regular or any subsequent work day or shift. Note: Lost Time refers to the inability~ perform the normally assigned job and shall be counted even though the employee is temporarily placed on a different job. Work Days Lost: ( column 3) The actual number of days the employee would have worked but could not because of an occupational injury or illness. The total number of days lost does not include the day of the injury ( or the first day of inability to perform the normal assi1nment because of illness); nor the day of return to full-time work at the normal assiinment; and also excludes days on which no regular work was scheduled for this employee. It does include as Lost Ti.rne all work days lost until the employee returns to his former or a new permanently assigned job. -- 8 - For employees not having a regularly sched- uled shift, i .. <?., certain truck drivers, construction workers, longshoremen, fa.rm labor, cc1.su2.l lc1.bor, etc., it may be necessary to estimate the nt.Unber of work days lost. Two-Visit Physici2n l'reatment Cises: ( column~) Injuries and illnesses, other than fata.lities and lost time cases, that require ~ or more visits to a physician. ( a) Occupational Injury An occup".tional injury is any injury such as a cut, fracture, sprain, amputation, etc., which results from a work acd~ent. (b) C.,ccupational Illnesses .3ecause occupational illnesses are rarely attributable to a specific incident, they should be reported in the year in which -- the illness w-3:s first dia3nosed and reported to the employer, For this report, an occupational illness of an emp!oyee is any abnormal physical condition or disorC:er, other than one resultin3 from an occupational injury, causet by- e::posure to enviroronental factors "ssocfa.te.:: with his employment. It inclu2es .:.cute and chronic illnesses or diseases which may be Ci:'.used by inhalation, absorption, in3e stio? or direct contact 2nd which can be inclucled in cate 1ories l throu.3h 7 listed in Cection -"1. (. Czte..,ories of fc.eport2ble Cccupational Illnesses The follov.,in 'I ..J listinoO- .._r, ives the cate u)'ories of occup2tion2.l illnesses and disorders that will ~e utilize~ for the purpose of classiiyin3 reportable illnesses. or purposes of information, e;:amples of each cat3ory are 6iven. .fhese are typical e.:2mples, however, and are not to be cons iderec to be the e:~clusive listing of the types of illnesses .and disorJers that are to be counted under each cate3ory. 1. GCGUPP-TIGNAL S:X.IN I.L33i~SZS or~ LISCF,L-:SRS Examples: Contact dermatitis, eczema, or rash caused by primary . irritants 2nd sensitizers or poisonous plants; oil acne; chrome ulcers; chentlcal burns or inflammations; etc. " r;us 1' .CLSE.ASES C.F TEJ; LUNCS ( Pneu.moconioses) Examples: Silicosis, asbestosis, coal v,orker1 s pneumoconiosis, byssinosis, and other pneu.moconioses. Examples: Pneumonitis, bronchitis, pharyn~itis, rhinitis or acute con_:estion due to chemicals, dusts, _;ases, or fumes; farmer 1 s lun_3; etc. 4. PCISCNIN~ ( Systemic Effects of Toxic Material~) E;~amples: Poisoninz by lea6, me:rcury, cz.c.~mium, e1.rsenic, or other metals; poisonin; ~y carbon mono_:ic~e, hyclro3en sul.icle or other _;as es; pois onin.3 bf ben:,,;ol, car0on tetrz.chloricle, or other or3anic solvents; poisonin,1 ~y insecticiC:e sprays such as parathion, lead arsenate; poisoninJ by other ch~micals such as form:;i.lcehyce, pl2.stics an~ resins; etc ..1. r.r::,;C.1.lLEf,S .i:., U-..I: 'fG P1-~Y.::ICJ.L J .3:1:NT~ ( C.. ther than J..,o_:.ic Iv1aterials) -1::~amples: ~-ieat stro:~e, sunstroke, heat e:.haustion anc other effects of environmental heat; free zin3, frostbite an.:: effects of e.:posure to low temperatures; caisso11 disease; effects of ionizin--r radiation ( isotopes, x-rays, ra~ium); effects of non-ionizinJ ~ raci~.tion ( welcin3 12.sh, ultra-violet rays, microwaves, sun:,urn)_; etc. E;~amples: Noise-induce~ he2 rin-:_'. loss; synovitis, tenosynovitis, and 'uursitis; Raynauci. 1 s phenomena; anc.' other conditions due to repeate-.: motion, vibration or pressure. 1. ALL C f.:....8F, OCCUPATICNAL ILLN::SS3S ~::am2les: Anthra.:, brucellosis, infectious hepatitis, mali,gnant anc beni_:n tumors, food poisonin.:;, histoplz.smosis, coccic'ioidomycosis, etc. ' ' 5. l Log of Reportable, Occupational Injuries and Illnesses ( Reduced) I1 Case Employee's Name Date of Class of Number (and Occupation at Time of Injury] Injury L Inj_ury or Illness I Brief Description of Injury or 111ness Fatalitie: Date of Death Extent o{ Injury or Illness Count each c::ise in onlv one of these classes of extent. l Non:Fatal Lost Time Cases Non-fatal Case, RcquiTing Date of Work-Days Physician Visits Only (,._;o Return to.. Lost From D::ivs Lost From Permanent Job) Permanent lob PeTmanent lob FiI3t'Vi~it Date Second Vis it L>aie ' ' ...... ...... , ' 1/ 1 For occupation:11 illness, d:ite of first day ol absence in connection with which it was diagnosed as an occup::itioMl illness and reoorted to the employer. y Enter one of these codes: A, Occupational injuries; B, Occup::ition:il s!;in diseases or disorders; C, Dust iliseascs of the lungs (pneumoconioses); D, Respir.itory conditiond due to toxic agents; E, Poisoning (Systemic effects of toxic materials); F, Disorders due to physical ~gents (other than toxic mate rials}; G, Di5orders dueto repeated trauma; H, /1.ll other occup.-tiom1I illnesses. Examples appear In Section 4. Note: M:liatenance of this log is intended only ns an :iid to accurllte completion of the annual summary. ' 0 ~l, :f.i.\,.;f'l \~ - 12 - 6, Annual Su:m.marx, An annual summary similar to Section 6. 1 shall be completed and posted in the employers establishment by February 15 of the follow. ing year, in a manner accessible to the employees. The posted summary shall be of sufficient size so as to be easily read by the employees. 7. Re porting Method 7. 1 Establishm.ents required to report will be determined by the Secretary of Labor. 7. 2 Method of reporting to be determined by the Secretary of Labor. 8. Data Output of the System The system is designed to provide, for the nation as a whole, estimates of: fhe total number of reportable work injuries and illnesses, the number of fatalities, the number of lost time cases, the number of work days lost, and the number of two-visit physician treatment cases. Also it is designed to provide, for each of these, a rate such as the number of two-visit phys.ician treatment cases per 100 employees. Either an estimate of the total or a rate, or both, could be provided for the follQwing: Each State, industry categories ( a total of about 1, 000 under the Standard Industrial Classification); size-of-establishment categories, and occupational injuries and occupational illnesses separately. Cross tabulations of the above could be provided in a large number of cases. For example the system might provide the total number of lost time cases from occupational illness in 1971 per 100 employees in 1.iiassachusetts chemical manufacturing establislunents with from 20 to l 00 employees. Individual establishment totals will be available for comparison to any of the aggregate figures or rates. t>. 1 ANNUAL SUMMARY - C970 OCCUPATIONAL INJURIES AND ILLNESSES XYZ MANUFACTURING COMPANY PLANT No. 1 3 III. Reportable Occupational Injuries and Illnesses i ( See instructions III. ) Fatalities Lost time cases NUTI1ber Work days of cases lost Two-vii,it Physician treatment c-ases (a) Occupational Injuries ( b) Occupational Illnesses . I"') I. Occupational skin diseases or disorders --< . 2. Dust diseases of the lungs ( pneumoconioses) ' ' 3. Respiratory conditions due to toxic agents 4. Poisonin (systemic effects of toxic materials) 5. Disorders due to physical agents ( other than toxic mate rials) 6. Disorders due to repeated traUilla 7. AH other occupational illnesses Total - - occupational illnesses ( 1- 7) { C) Total -- Occupational Iniuries and Illnesses I I I I I IlI ! I I ! - I ! -r' [ --- v J~ j:/~) Exhibit II . Report to the American National Standards Institute from the Study Group on a National System for Uniform Recording and Reporting of Occupational Injuries and Illnesses This report records the beginning and work of the study group, the assumptions under which it operated, and the principal matters it considered. Study Group Charge Secretary of Labor J. D. Hodgson ( then Under Secretary) noted, in a letter to the American National Standards Institute in December 196 9, that the proposed Occupational Safety and Health Act included a proposed national system for the collection of occupational accident and health statistics. He expressed concern over the appropriateness a..nd applicability of ANSI Standard Z 16.1-1967, l\/Iethods of Recording and Measuring Work Injury Experience, for the broad universe of employees subject to the jurisdiction of the Act particularly with reference to the complexity of Z.16. 1 and its treatment of health questions. Mr. Hodgson requested that ANSI initiate a review and eyaluation of the effectivenes-s and application of Z 16. 1 as the national standard for injury statistics collection. An informal conference of injury statis_tics experts met at ANSI headquarters on January 5, 1970, to review the question. The conferees agreed that there was substance to Mr. Hodgson? s concern and proposed that a study group be formed with the following charge: Review available reporting methods and standards of reporting injuries on a nationwide basis and if necessary develop a simple method of reporting injuries. fhis shall be in the form of recom.rnendations to the Standards Institute. The conferees based their proposal on considerations including the following: Z 16. 1 has grown complex through efforts to make it equitable in varying circumstances, but the complexity has led to inequity for small reporters who do not know the full standard. It is now too complicated for a mandatory national reporting system. - 2- For establishments and companies with good safety re~ords, Zl 6; 1 does not reflect trends in injury experience adequately. Zl6. 1 is not adequate for the recording of health experience, e.g ., noise and occupational illnesses. The conferees also found that the Zl6. 1 Standard could not be separated from its use, and proposed l"eview of reporting systems and thei.r samples, the detail in which statistics are required, and nature of reports in a national system. President Francis L. LaQue of ANSI accepted the report oi the conferees and appointed a study group to make a report to the Institute in 90 days. Review of Problem The study group held full-day meetings on January 16, February 3 and 17, March 9 and 23, April 0, 7 and 23 and July 28. Consultants, par- ticularly in the field of occupational illness, were invited to sit with the group and provided a considerable amount of useful information and advice. Members of the ANSI staff participated in the work and provided brief minutes of the meetings. Although the study group gave brief attention to workmen1 s compensation statistics, disability statistics of the Social Security Administration, and current planning by the Bureau of Mines, it was agreed that the system to be considered must be more like the current establisrunent statistics systems of the Bureau of Labor Statist"ics and the National Safety Council. Current BLS and NSC statistics were found to suffer from the problems of ANSI Zl6. 1 noted by the earlier conference, from inadequate samples, and from not reflecting experience by size of establishment. fhe study group recommends that every employer covered by the Act be required to keep a record of each reportable occupational injury and illness ( including fatality), and that he be required to compile an annual smnmary of the individual records and post it by February IS of the following year within the establishment in a manner accessible to the employees. Not all the employers should be required to provide reports to the Federal Goverrunent, perhaps nLS, for statistical purposes, however, a well-designed sample would provide sounder ::;tatistic.:, than a complete enumeration of covered employers. Subject to technical review by sampling statisticians, the study zroup estimates that an eventual sample of about 1 million reports would provide adequate national and State statistics by industry and size class. - 3- System Concepts Bea.ring in mind the points on which the L. 16. 1 Standard was criticized, the study group set about devising a system that would be simple, sensitive, and meaningful; would reflect occupational d:l.sease experience; and would be usable in a very large-scale survey. The items to be reported were defined a.nd redefined several times in attempts to come closer to this ideal. fhe system assUines that each establishment will maintain records of reportable injuries and illness and will make and post an annual summary. A sample of establishments will make annual reports including data from the summary with location, employment, man-hours. and activity data required for the statistics. It is envisaged, however, that some establishments will be required to provide variations of this report, on a more frequent basis or including additional data, to _meet information requirements for administration of the legislation. The study group believes that reports should be held in confidence within the area of administration of the legislation. A sta~ement might be made that 11Individual es"tablishrnent _reports will not be made public and no statistics will be published in a way that permits identification of an individual establishment or deducation of its reports. fhe reports are to be available for statfstical compilation, for the direction of inspection and consultation services, and for administration of the Act. 11 The study group felt that the system should provide insofar as possible a sensitive measure. Counting compaz:atively numerous minor incidents gives a more sensitive measure. CountinS! comparatively rare major incidents 3ives a less sensitive measure. Unfortunately, it is not. practical to count every accident and so the most sensitive measure cannot be us ed. The crucial task of the stucly _1roup was to choose a me a.sure which on the one hand would be sensitive and on the other practical for a large number of employers. Such a measure must be defined in terms of tl1e e:<tent of the injury of illness. Then all injuries or illnesses of that or greater extent would be 11 reportable, 11 a term the study group adopted. fhe 6roup a3reed that traditional frequency and severity rates expressed in terms of millions of man-hours worked are abstract concepts not readily understood by management and others concerned with the protection of workers, Consequently, the study group decided that a more meanin:3"ful measure of rates would be 11 injuries per 100 employees per year 1' rather than per million man-hours worked, These rates shoulci be in terms of 100 full-time employees. rhe system was simplified by eliminating the traditional exceptions and e:;,emptions of Zl6. l and by reducing the number of decisions that have to be made by those required to keep records. For example, instructions for use of this system are contained on 4 typewritten . pa:;es compared to the ~O printed pa3es of ~16. 1. Statistics from the system proposed would include some estimated numbers, as the number of fatalities or the number of reportable injuries or illnesses. For comparison purposes, however, experience must be reflected by rates. The study 3roup re cornmencls that the primary base of such rates be the numbe-rs of man-hours at -risk, and that they be e:,:pressed in terms of a base of 100 :full-time employees. Measurements of the severity of injury and illness that apply arbit-rary num.bers of days or deaths and permanent impairments are felt to be too comple:c. and obscure fo-r ::;eneral comprehension and fous tl1e recommended system does not include abritrary charges .. l'he recommendation of the .stucly group provides or a count of work days lost, but does not provide an all-over severity measure. It is felt that, for purposes of prevention of future losses, the random or accidental factors affe ctin3-the extent of disability are of little importance as compared to the occurrence of an occup'ational injury or illness. Terms fhe Study Group defined t.i1e followinJ terms to be part of the reporting system. Reportable Occupational Injuries and Illnesses are defined in terms of the e.:tent of the injury. Three classes were defined: Fatalities are included, as t!1ey are in all measures. Lost rime Cases are C:efined in a variant of a definition used for over :JO years, the inability of the employee to perform his normal assi3nment clurin3 a day or shift alter t.ie clay of injury. fwo .. Visit Physician Treatment Cases are defined as those in which the re is neither death nor lost time, but two or more visits to a physician are require cl. rhe se measures of e::tent are equallf applicable to injuries an'd illnesses. Io distin2uish between the traditional terms 0 ''accidental injury" a.n<l "occupational disease, 11 the study 6 roup sou2ht an understandable title for each class. - :J - Replacing accidental injury the 3roup chose Occupational Iniury defined as those which arise from work accidents. The term occupational illnesses was used as broader tl1_an 11disease. 11 "Occupational injury 11 was defined very briefly, but "occupational illness 11 is defined at len!5th, divided into seven cate,:::-ories, and illustrated by e~,:amples for each of the cate3ories. These measures are intended to encoura3e uniform and complete reportin:1 in spite of varying inclusions in workmen's compensation laws and the lack of a .t5eneral consciousness of the variety of occupational illnesses. The combined class of occupational injuries and illnesses is defined very simply as 11 any disability or permanent impairment to an employee which results from any e;cposure in the work environment'' and meets tne e.~tent criteria mentioned above. !'he study group recommends strongly a3ainst specific e::ceptions and e::.emptions such as those in 2.16. 1, which are regarded as a serious fault of that Standard. The conference that proposed tne study 3roup made reference to noise and hearin:; as well as occupational disease under the general headin~ of health. It is the findin:; of the stu<ly ~roup that not all occupational noise-induced hearin_g loss problems are susceptible to measurement by" tl1e recording the reporting system proposed. Other tecnniques may' be required to identify problems in tllis area. Establishments to be Covered by Reoortinri; System The number of employers who will be subject to tne le3islation when enacteC: was not known. rhe number of _farms and nona:;ricultural establis1rments is estimateci to be :.> million, but this number includes -an undetermined number of retail and service establishments counted on the basis of one per county. There are aclvanta3es to havinG separate recorcis maintained for such establishrn.erits rather than havin:; county-wide records. The number would be considerably re<lucecl for survey purposes if the le.3islation or re_,ulations e:--:empted from reportin~ or record-keepin6 establishments wit11 small number of employees. fhe basic unit for wi1ich it is proposeci that re cords 0e maintained and reports made is tj_1e llestablishment 11 as defineJ in the Standard Indust-rial Classification of the Office of lv.(ana3cment and 3udJet. Briefly, it is an economic unit which produces ~cods or services. Cienerally, it is at a sin3le physical location ancl is en3a~ed in only one, or predominantly one, type of economic activity for w11ich an industry code is applicable. Separate economic activities at a sin3le location are re~arded as separate establisj_unents when such activities are not ordinarily associated in a sin:;le location, tl1e SIC does not have an industry description for such combinations, the employment in each activity is si:;nificant, and reports can be prepared on establishznent type data. Study Group on a National System for Uniform F.ecordin.3 and Reporting of Cccupational Injuries and Illness l\i.:.embers lv.caurir.e E". Jresnahan, Chairman ~ureau of Lacer Statistics Alternate: Lyle R. Schauer .:Cavid Curley Aetna Life and Casualty Company ..:;eor Je C. Guentner .3urea.u of Labor Standards Alternate: veorge J. Yatsko :;:-:r. Gene 1'dller National Safety Council Alternate: Sidney :i:. Smith Paul L. iviichael Pennsylvania State University Geor3e H. R. Taylor AFL-CIC John G. Thodis 1\t..ichi3a.n Gepartment of Labor James 7. Van Namee V! estin3house Electric Corporation :t7'or the American National Standards Institute henry J. Lamb ~or;e V 3owen Consultants Bureau of Cccupational Safety and _--~ealth, IEW N1arcus Ni. Key, lv...L Victoria .L'raslco .J:dv1ard F. Sea .,.,le Vernon r~ose Social Security Administration Lawrence L. Ha:ier